On 6 July 2026, the Indonesian Government officially enacted Ministry of Environment / Environmental Control Agency Regulation No. 10 of 2026 on the Carbon Unit Registry System (Sistem Registri Unit Karbon or SRUK).
The regulation establishes Indonesia's official registry for recording every carbon unit issued and traded, whether domestically or internationally. It serves as the country's centralized record of carbon transactions, ensuring transparency, accountability, and traceability throughout the carbon market.
This article explains what the Carbon Unit Registry System (SRUK) is, why it is necessary, and how it works under the latest Indonesian carbon trading framework.
Under Article 1 point 12 of Ministry Regulation No. 10 of 2026, the Carbon Unit Registry System (SRUK) is a system that provides and manages data and information relating to Carbon Units used in implementing Carbon Economic Value (Nilai Ekonomi Karbon or NEK) instruments.
Carbon Economic Value refers to the value assigned to greenhouse gas emission units generated through human activities and economic activities.
To better understand SRUK, think of it as a bank account for carbon units instead of money.
Rather than recording cash deposits and withdrawals, SRUK records the ownership, issuance, transfer, utilization, and retirement of carbon units generated by businesses or organizations that successfully reduce greenhouse gas emissions. Every carbon transaction including buying, selling, transferring ownership, or retiring carbon units, must be recorded in SRUK. This enables the government and market participants to verify every carbon unit throughout its lifecycle while ensuring that all transactions remain transparent and traceable.
According to Article 2 of Ministry Regulation No. 10 of 2026, the Carbon Unit Registry System has three primary objectives:
SRUK serves as Indonesia's national database for carbon units by collecting, maintaining, and organizing information relating to all registered carbon units under the Carbon Economic Value framework.
A centralized registry allows the government to monitor carbon activities across sectors and maintain consistent national records.
SRUK supports Indonesia's commitment under the Paris Agreement by helping the country achieve its Nationally Determined Contribution (NDC) targets. Through accurate recording and monitoring of carbon units, the government can better measure greenhouse gas emission reductions and evaluate progress toward Indonesia's climate commitments.
Perhaps the most important function of SRUK is preventing double counting.
Double counting occurs when the same carbon unit is issued, claimed, transferred, or used more than once. This could happen if one emission reduction is simultaneously recognized under multiple certification schemes or claimed by multiple parties.
For example, suppose a company successfully reduces its carbon emissions and receives carbon units. Those emission reductions should not be:
If this were allowed, a single emission reduction would be counted twice, undermining the integrity of carbon markets.
By recording every carbon unit and tracking every ownership change, SRUK ensures that each verified emission reduction is counted only once, thereby maintaining the credibility of Indonesia's carbon trading system.
The Carbon Unit Registry System is implemented under Ministry of Environment / Environmental Control Agency Regulation No. 10 of 2026, which serves as an implementing regulation of Presidential Regulation No. 110 of 2025 on Carbon Economic Value Instruments and National Greenhouse Gas Emission Control.
In simple terms:
Together, these regulations form the legal foundation for Indonesia's carbon registry and carbon trading system.
Under Article 4 of Ministry Regulation No. 10 of 2026, the Carbon Unit Registry System records data relating to three primary Carbon Economic Value (NEK) instruments.
Carbon trading refers to the buying and selling of carbon units, either through Indonesia's Carbon Exchange or by way of direct transactions between eligible parties.
Every carbon unit traded must be registered in SRUK to ensure transparency, traceability, and proper ownership records.
Result-Based Payments (RBPs) are financial incentives awarded to entities that successfully reduce greenhouse gas emissions after the reductions have been independently verified.
Unlike carbon trading, where carbon units are sold to buyers, Result-Based Payments reward verified climate achievements with financial compensation.
A Carbon Levy is a government-imposed charge on goods, services, or activities that have the potential to generate carbon emissions.
The levy is intended to encourage businesses to reduce emissions while supporting Indonesia's broader climate policies under the Carbon Economic Value framework.
One of SRUK's distinguishing features is its use of a decentralized network system.
Rather than relying on a single centralized authority to manage all data, SRUK enables authorized government institutions and relevant stakeholders to manage and exchange information according to their respective functions and legal authority. This decentralized approach improves system flexibility while reducing dependence on a single administrative body.
In addition, Article 5 of Ministry Regulation No. 10 of 2026 specifies several core characteristics of the Carbon Unit Registry System.
According to Article 7 of Ministry Regulation No. 10 of 2026, SRUK users are divided into four categories.
This group includes:
These authorities oversee the implementation and administration of Carbon Economic Value instruments in Indonesia.
This category includes government institutions, companies, and members of the public that carry out climate change mitigation activities. Businesses participating in carbon reduction projects, emissions trading, or other Carbon Economic Value mechanisms are required to register and manage their carbon units through SRUK where applicable.
Independent validation and verification bodies assess whether greenhouse gas emission reduction claims comply with applicable standards. To perform this role, these organizations must be legally established and accredited under the relevant regulations. Their involvement helps ensure that carbon units recorded in SRUK are supported by credible and independently verified emission reductions.
Members of the public and businesses may access certain information available through SRUK. However, access is limited to information classified as public. Confidential commercial information including transaction prices, buyer identities, industrial secrets, and contractual documents is protected from public disclosure.
The regulation distinguishes between domestic carbon trading and cross-border carbon trading, each of which is subject to specific legal requirements.
Domestic carbon trading may be conducted through two mechanisms:
Cross-border carbon trading involves additional regulatory safeguards, particularly the concepts of Authorization and Corresponding Adjustment. In simple terms, if Indonesian carbon units are transferred to another country and used toward that country's climate commitments, Indonesia must deduct the corresponding emission reductions from its own national greenhouse gas inventory.
This adjustment prevents the same emission reduction from being counted by both Indonesia and the purchasing country, thereby eliminating the risk of double counting and maintaining the integrity of international carbon markets.
Under Ministry Regulation No. 10 of 2026, every carbon trading activity whether conducted domestically or internationally must be registered through the Carbon Unit Registry System (SRUK) and recorded in Indonesia's Carbon Exchange.
For Greenhouse Gas (GHG) Emission Offset activities, the regulation establishes a structured registration process to ensure that emission reductions are properly verified before carbon units are issued.
The registration process generally consists of the following stages.
The project developer or responsible business entity must first create an SRUK account and submit both general and technical project information.
The technical information includes, among other things:
This information serves as the foundation for evaluating the proposed mitigation project.
Applicants must then submit either:
depending on the applicable project scheme.
Once the document has been submitted, the relevant minister or authorized authority will issue a notification confirming receipt of the application.
The proposed mitigation project must undergo validation and verification by an accredited independent validation and verification body.
During this stage, the independent verifier assesses whether:
Following the assessment, the verifier issues a validation and verification report.
If the project successfully passes the verification process, the relevant authority may issue a recommendation or approval for the project.
The verified emission reductions are then converted into officially recognized carbon units, allowing them to be used for emission offset purposes or traded in accordance with the applicable regulations.
For carbon units intended to be transferred abroad, the regulation imposes four additional procedural steps.
These include:
These additional procedures ensure that carbon units transferred overseas are properly deducted from Indonesia's national greenhouse gas inventory, thereby preventing double counting between Indonesia and the purchasing country.
The regulation also establishes two key deadlines for emission offset transactions.
Every emission offset transaction must be recorded in SRUK within two working days after the transaction takes place. This requirement ensures that ownership records remain accurate and that the registry reflects the latest transaction status.
For international carbon trading, the required Authorization must be issued within 15 working days after the relevant recommendation has been received by the competent authority. This timeline provides greater certainty for businesses participating in cross-border carbon markets.
Ministry Regulation No. 10 of 2026 classifies Carbon Unit Certificates into two categories:
An SPE GRK is an official certificate issued by the Indonesian Government confirming that a business activity or project has successfully achieved verified greenhouse gas emission reductions.
The certificate may be used for various purposes, including:
As a government-issued certificate, SPE GRK represents the official recognition of verified emission reductions under Indonesia's Carbon Economic Value framework.
A Non-SPE GRK is a carbon certificate issued under an international certification scheme after obtaining approval from the relevant Indonesian authority.
This type of certificate facilitates participation in international carbon markets while ensuring compliance with Indonesia's regulatory framework.
Both SPE GRK and Non-SPE GRK certificates must include essential information to ensure transparency and traceability.
The mandatory information includes:
Including this information allows every Carbon Unit to be uniquely identified, verified, and tracked throughout its lifecycle.
Ministry Regulation No. 10 of 2026 requires Indonesia's Carbon Exchange to be fully integrated with the Carbon Unit Registry System. This integration ensures that every carbon transaction recorded on the exchange is automatically synchronized with SRUK in real time, enabling accurate and up-to-date records across both systems.
Through this integration, SRUK continuously records and updates:
Each recorded transaction must include, at a minimum:
This integrated system strengthens transparency, reduces administrative inconsistencies, and supports the integrity of Indonesia's carbon market.
Ministry Regulation No. 10 of 2026 provides administrative sanctions for business operators and responsible parties that fail to comply with the requirements governing the Carbon Unit Registry System (SRUK). These sanctions are intended to preserve the integrity, transparency, and credibility of Indonesia's carbon market by ensuring that carbon units are issued, registered, and traded in accordance with applicable laws. Depending on the nature of the violation, the following sanctions may be imposed.
The government may revoke a previously issued Greenhouse Gas Emission Reduction Certificate (SPE GRK) if it is found that the certificate was obtained or used in violation of the applicable regulations.
Without a valid certificate, the associated carbon units may no longer be recognized for carbon trading or other Carbon Economic Value (NEK) purposes.
The responsible business entity may also face the permanent closure of its SRUK account.
Once an account is permanently closed, the entity can no longer access or utilize the Carbon Unit Registry System for future carbon-related activities.
Where carbon units have been manipulated or improperly used, the responsible party may be required to:
This requirement is intended to maintain the environmental integrity of Indonesia's carbon reduction efforts and ensure that any improperly claimed emission reductions are appropriately remedied.
In addition to the sanctions above, the relevant minister may impose other administrative penalties in accordance with the applicable laws and regulations. The specific sanction imposed will depend on the nature and severity of the violation.
Through these enforcement measures, the government seeks to ensure that all carbon unit registration, issuance, and trading activities are conducted honestly, transparently, and in compliance with Indonesia's carbon trading regulations.
Ministry of Environment / Environmental Control Agency Regulation No. 10 of 2026 was signed in Jakarta on 2 July 2026 by the Minister of Environment and Head of the Environmental Control Agency, Moh Jumhur Hidayat, and was officially promulgated on 6 July 2026.
The regulation entered into force on 6 July 2026, the date of its promulgation.
1. What is the difference between SRUK and SRN PPI?
Although both systems support Indonesia's climate change initiatives, they serve different purposes.
SRN PPI (National Registry System for Climate Change Control) records a broad range of activities, programs, and resources related to climate change mitigation and adaptation in Indonesia.
SRUK, on the other hand, specifically records Carbon Units issued, utilized, and traded under Indonesia's Carbon Economic Value (NEK) framework.
In short, SRN PPI functions as Indonesia's broader climate registry, while SRUK focuses specifically on carbon units and carbon trading activities.
2. Who manages the Carbon Unit Registry System?
SRUK is administered by the Minister of Environment / Head of the Environmental Control Agency (BPLH).
The system is supported by a management team consisting of representatives from relevant ministries and government agencies responsible for implementing Indonesia's Carbon Economic Value framework.
3. Can the public access information stored in SRUK?
Yes. Certain information contained in SRUK is available to the public.
However, commercially confidential information is protected and cannot be accessed by the public.
Confidential information includes, among other things:
This approach promotes transparency while safeguarding legitimate business interests.
4. What is a Corresponding Adjustment?
A Corresponding Adjustment is a mechanism designed to prevent double counting in international carbon trading. For example, if a Carbon Unit generated in Indonesia is sold to another country and used toward that country's climate commitments, Indonesia must deduct the corresponding emission reduction from its own national greenhouse gas inventory. This ensures that the same emission reduction is counted only once and is not simultaneously claimed by both Indonesia and the purchasing country.
The Carbon Unit Registry System (SRUK) represents a significant milestone in Indonesia's efforts to establish a transparent, credible, and internationally recognized carbon trading framework.
By providing a registry that is transparent, traceable, real-time, and designed to prevent double counting, SRUK strengthens confidence in Indonesia's carbon market while supporting the country's commitment to achieving its Nationally Determined Contribution (NDC) under the Paris Agreement. For businesses operating in sectors such as energy, forestry, manufacturing, mining, and other emission-intensive industries, understanding SRUK is no longer optional.
Compliance with the regulation is becoming an essential part of both legal risk management and long-term sustainability strategy. Because every business has different obligations under Indonesia's carbon trading regulations, understanding the applicable legal requirements from the outset is critical to avoiding future compliance risks.
CPT Corporate provides legal advisory and business licensing services to help companies navigate Indonesia's evolving carbon trading regulations, understand their compliance obligations, and ensure their business operations remain fully aligned with applicable Indonesian laws.
The Indonesian Government has officially enacted the Minister of Transportation Regulation (Permenhub) No. PM 4 of 2026, which introduces significant amendments to the regulatory framework governing multimodal transport services in Indonesia.
Pada 6 Juli 2026, pemerintah resmi mengundangkan Permen LH 10/2026 tentang Sistem Registri Unit Karbon, yang selanjutnya disingkat SRUK.
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